My letter to the CA Attorney General

To Whom it May Concern:

As you may or may not be aware, California and the nation are currently under attack by unlicensed taxi services that are being barely regulated by the CPUC.  These services have overrun the city streets with thousands of questionably insured vehicles driven by untrained drivers without the requisite licensing to pick up on-demand passengers for compensation, acting as de-facto taxicabs.

I have collected over 3400 unique license plates of vehicles participating in these TNC services and hundreds of pictures of these vehicles on our streets.  According to the CA Dept of Insurance, ( TNC drivers may not have coverage if their insurance policies have a livery exclusion.  These TNC drivers are not informing their insurers of their activities and when the insurers discover that a driver is participating as a TNC driver the insurer denies claims and cancels policies.  It has also come to my attention recently that the insurance investigators are actively referring these cases to the District Attorney for insurance fraud.  Compounding the problem is the lack of communication the TNC companies have with their drivers regarding insurance requirements under state law, as the CPUC erroneously decided that these drivers could have basic personal insurance in-between TNC booked rides and the TNC’s insurance policy could cover them while in-ride.  

These companies are actively recruiting drivers and customers via social media and from taxis, sometimes even stopping people before they get to a taxi and have them download the app and order a ride instead of taking one of the waiting taxis.  In our opinion this is blatant violation of CA BPC 17045 regarding secret payments, rebates et. al.

One of the companies has not only stated that they intend to “crush” the taxi industry out of existence, but they recruit those same drivers they “crushed” out of business, to come work for them and even arranges financing for new vehicles specifically for TNC services.  This is a violation of the CPUCs decision first that the vehicles may not be used primarily for commercial passenger use or purchased for same.  With Uber brokering the sale of vehicles without an auto-dealer license from the DMV, and staff acting as salespeople, they are violating yet another state law.

In fact this is just the beginning of a very long list of state and local laws being violated by these companies and their drivers.

Below is a list of just a few of the laws we have found, that I believe these companies and drivers to be in violation of.

Title 49 USC 13102 (19-22)

FED Criminal Code Title 18 sec 1961 {racketeering, bribery and fraud}

CPUC 103301.5; 103301.6; 5413.5(b) 

Cal Gov Code 53075.8 (c); 53075.9 (b-c)

CA BPC 17200-17210; 17045  {unfair business practices}

SFTC 1105(a)1  {operating a for hire passenger vehicle or company without a permit}

CA VC 23123 {mobile device use while driving}


Here are links to recent articles detailing some the offenses of drivers and companies alike.

Bottom line, I allege that (under my limited knowledge of the law) these companies, their officers, and participating drivers are conspiring to profit from criminal activity including insurance fraud, unfair competition, unlicensed taxi service, and coercion to commit fraud.   

It is truly in the best interest of the law abiding citizens and businesses of California for these companies to be investigated and prosecuted for the allegations described here along with other illegal activities we do not know about.

Trevor Johnson


2 thoughts on “My letter to the CA Attorney General

  1. Yawn… u must be a dinosaur with a rotary landline phone, an AOL account and a dial up modem. Or, you own a cab company, Or you simply ignore the benefits of innovation and modernism as you write a blog, which hurts my brain.

    Lyft et al empower the individual. They are competition. Competion is good for all of us. If you have a license to drive a car, u can drive. U can drive a friend, you can drive all day. You could even drive all your friends all day. Your friends could even give u gas money and a little more to say thanks for the service. God forbid that becomes a business model!

    Pretty simple really: you want a real person who cares about your journey like a friend who picked u up, Lyft; u want a reliable, sleek ride in 10 minutes with limo care for a fraction of the cost, Uber; you wanna pay a ridiculously high starting fare for the pleasure of leaving the LAX terminal, and the pleasure of sitting behind smeared cop car glass with talking holes and a driver mid argument with his wife via his blue tooth in a foreign language? Hail that cab!

    1. Actually I have many many gadgets and was on the internet before most people knew it even existed. My first email was I had to dial in or telnet in to get to my unix shell. That was in 1993. So definitely not a dinosaur. Breaking the law is not innovation especially when you copy someone’s product that does the exact same thing legally. Taxis had apps before you had a smartphone and well before Uber. Would you want someone to undercut your legal business with an illegal version? Probably not. If you want I can do your job for you and I’ll charge your employer half of what they pay you. I’ll call it jobsharing.

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